The Commonwealth of Virginia’s November 2010 Chesapeake Bay Watershed Implementation Plan included its regulatory plan to ensure MS4s implemented necessary pollutant reductions.  This regulatory plan details the back-end dominated pollutant reduction MS4 permitting strategy that DEQ selected to employ over three five-year VPDES permit cycles, beginning in 2013.  On March 12, 2020, Virginia Governor Ralph Northam declared a state of emergency in response to the continuing spread of COVID-19 across the Commonwealth.  Governor Northam’s declaration underscores the historical impact the pandemic has had on Virginia’s citizens, businesses and government agencies.  Specific to MS4 operators, COVID-19 has dramatically challenged implementation of pollutant reduction strategies necessary to meet the time frame published in DEQ’s MS4 regulatory plan.  Unexpected disruptions to both planned short-term and long-term funding strategies caused by lost revenue, fiscal resource reprioritization or both have made meeting the back-end dominated pollutant reductions even more burdensome to MS4 permit operators.  One stopgap measure currently available to MS4 operators to overcome this unforeseen obstacle is the acquisition of nutrient credits through private exchanges with wastewater treatment facility operators.  While not an ultimate solution, MS4 operators can potentially use private exchanges to buy valuable time to meet MS4 nutrient reduction requirements while recovering from COVID-19 impacts.  This presentation summarizes the opportunities and constraints associated with nutrient credit acquisition through private exchanges.